36 CFR Parts 1190 and 1191 ADA and ABA Accessibility Guidelines - Preamble (Discussion of Comments and Changes)

The Board has clarified requirements for vertical access to mezzanines. While elevators, where provided, must serve all stories, including mezzanines where provided, ADAAG has not been clear on whether some form of vertical access is nonetheless required to a mezzanine level where no elevator is provided, such as a one-story building. Since mezzanines are elevated at heights similar to a full story, access by ramp or certain platform lifts may not provide a practical alternative. The final rule includes an exception at 206.2.4, Exception 3 stating that an accessible route to mezzanines is not required in facilities that are not subject to the requirement for an elevator, including one story buildings and those that qualify for the elevator exemption.